emphasized the importance of transformativeness in its fair use analysis of the accused infringers' parody of "Oh, Pretty Woman," which the case involved. In parody, as the Court explained, the transformativeness is the new insight that readers, listeners, or viewers gain from the parodic treatment of the original work. As the Court pointed out, the words of the parody "derisively demonstrat[e] how bland and banal the Orbison [Pretty Woman] song" is. Leval article The modern emphasis of transformativeness in fair use analysis stems from a 1990 article by Judge Pierre N. Leval in the Harvard Law Review, Toward a Fair Use Standard, which the Supreme Court quoted and cited extensively in its Campbell opinion. In his article, Judge Leval explained the social importance of transformative use of another's work and what justifies such a taking: Arriba Soft, Perfect 10, and Authors Guild The concept of transformativeness initially developed in relation to fair use of traditional works: translations of literary works, adaptations of musical works, and changes of medium for pictorial works. But in the 21st century, courts have also applied the "in a different manner or for a different purpose" rationale in Internet and computer-related works. In such cases, as illustrated by Kelly v. Arriba Soft Corporation Perfect 10, Inc. v. Amazon.com, Inc., and Authors Guild, Inc. v. Google, Inc., the courts find a derivative-work use (such as that of thumbnails in an image search engine, for indexing purposes) or a copy of text (to facilitate key-word indexing) transformative because it provides an added benefit to the public, which was not previously available and might remain unavailable without the derivative or secondary use. Ninth Circuit decisions The Ninth Circuit explained this in the Perfect 10 case: Google's use of thumbnails is highly transformative. In Kelly we concluded that Arriba's use of thumbnails was transformative because "Arriba's use of the images served a different function than Kelly's use—improving access to information on the Internet versus artistic expression." Although an image may have been created originally to serve an entertainment, aesthetic, or informative function, a search engine transforms the image into a pointer directing a user to a source of information. Just as a "parody has an obvious claim to transformative value" because "it can provide social benefit, by shedding light on an earlier work, and, in the process, creating a new one," a search engine provides social benefit by incorporating an